CMS Bureau Francis Lefebvre (Chair)

CMS Bureau Francis Lefebvre (Chair)

(Organisation) name: CMS Bureau Francis Lefebvre

Acronym: CMS BFL

Transparency register

identification number:

236306318725-94

Website: www.cms-bfl.com

Category: Corporate

and more precisely: Professional consultancies

Countries/Areas

represented:

International

Goals / remit / activity of

the organisation:

With around 380 lawyers CMS Bureau Francis Lefebvre is one of the very top multi-disciplinary law firms in France. CMS BFL is a member of CMS, an organisation of 10

major independent European law firms established in 33

countries. The offices are mainly in Europe, but also in

North Africa, Middle East, Asia, and South America.

The firm is structured around 3 main fields of expertise

(tax, employment and business law). Particularly, it has a

large team (more than 200 lawyers including 61

partners) offering expertise in all key areas of tax,

including disputes, domestic and international M&A,

restructuring, financing, real estate, transfer pricing, VAT

and local taxes. In addition to work with corporate

clients, it also advises individuals on private tax matters.

The international taxation department to which Bruno

Gibert belongs, counts more than 50 lawyers, including

16 partners. Europe (of which Germany), Africa (of

which Morocco), North America (of which USA), or even

South America (more particularly Brazil) are part of

geographical areas for which the international

department expertise is the most notable.

http://www.cms-bfl.com/

If applicable, sectors

represented:

Industry

Level of interests

represented:

II. CHAIRMAN OF THE EU JTPF – SHORT CV:

Name and surname: Bruno Gibert

Nationality: French

Position: Attorney at Law, Partner in the law firm of CMS Bureau Francis Lefebvre - International taxation / Transfer Pricing Head of the CMS Transfer Pricing group

Title:

Current professional

experience & interest in

transfer pricing:

Mr. Bruno Gibert is Partner in the law firm of CMS

Bureau Francis Lefebvre - International taxation /

Transfer Pricing.

In this capacity, particularly involved in advising on transfer pricing policy and in dispute resolution in the field of transfer pricing for major French and international firms. Special focus on (i) mutual agreement procedures and arbitration and on (ii) the negotiation of advance pricing agreement). Clients in the automotive industry, pharmaceutical industry, packaging, IT industry, food industry, consumer goods industry.

Previous professional

experience:

Mr. Bruno Gibert has 16 years' experience in the

government service, where he was in charge of

international tax affairs (negotiation of tax treaties with

foreign countries, OECD and EU work, and competent

authority). He used to be co-chairman of the OECD

Forum on Harmful Tax Practices (1996 to 2001).

Main publications in

transfer pricing:

Bruno Gibert is the author of a report to the French

government on tax security in France in 2004 and co-

author of two other reports to the French government,

one on intangible assets (2006) and one on how to

improve the commentary on French tax law (2010). He is

also the co-author of the chapter on rulings of a book on

French tax procedures (published in 2005 and updated

in 2008), a book on transfer pricing in France (Ed F

Lefebvre, 2010) and the author of the chapter on France

of the book Transfer Pricing and Dispute Resolution

published in 2011 and of the chapter on the mutual

agreement procedure of a book on the OECD Model

Convention (Ed Francis Lefebvre 2014). He regularly

publishes articles on international tax matters in French

and international publications.

BDI (Federation of German Industries)

(Organisation) name: BDI (Bundesverband der Deutschen Industrie e.V. -

Federation of German Industries)

Acronym: BDI



1771817758-48

Website: http://www.bdi.eu

Category: Association

and more precisely: Business association

Countries/Areas

represented:

Germany


the organisation:

The BDI (Federation of German Industries) is the

umbrella organization of German industry and industry-

related service providers. It speaks on behalf of 36

sector associations and represents over 100,000 large,

medium-sized and small enterprises with more than

eight million employees. The BDI ensures that industry

speaks with one voice vis-à-vis political institutions at

national, European and international level. It commands

a wide network in all key markets and international

organisations. The BDI provides political flanking for the

opening-up of international markets as well as

information and economic policy advice on all topics

relevant to industry, among them tax and financial

policy.


represented:

Industry

Level of interests

represented:

National (Germany) Regional/local

http://www.bdi.eu/

II. DESIGNATED EXPERT – SHORT CV:

Name and surname: Philipp Kaiser

Nationality: German

Position: Head of Global Transfer Pricing, Bayer

Title:



transfer pricing:

Philipp is responsible of transfer pricing for all sub-

groups of Bayer (Bayer CropScience, Bayer Healthcare

and Bayer MaterialScience).


experience:

Philipp has more than 10 years of experience in the area

of transfer pricing. Before joining Bayer in 2011, he

spent 6 years with Ernst & Young's transfer pricing

expert group in Düsseldorf/Germany and New York. His

experience covers preparation of transfer pricing

documentations (Global and EU- Master file, US, etc.),

transfer pricing audits on a global scale, several

competent authority procedures (Mutual Agreement

Procedures and Advance Pricing Arrangements),

strategic transfer pricing planning including business

model effectiveness and intellectual property planning.

Philipp has strong focus and in-depth knowledge of the

pharmaceutical, agricultural and chemical industry


transfer pricing:

Academic background /

Degrees and

qualifications:

Master degree in Economics (Technical University of

Dresden, Germany; École Supérieure de Commerce

Saint Étienne, France)

Other memberships and

representations in

groups/committees

dealing with transfer

pricing, corporate tax or

related matters:

III. DESIGNATED ALTERNATE – SHORT CV:

Name and surname: Julia Stoltenberg

Nationality: German

Position: Global Lead Transfer Pricing SAP Group/ SAP SE

Title:



transfer pricing:

Responsible for the management of transfer pricing

matters and the roll out of global guidelines within the

SAP group, with businesses in more than 130 countries

and a significant intercompany volume. Strategic

transfer pricing planning as well as successful support of

transfer pricing audits within the SAP group worldwide.

Comprehensive experience in the area of intangibles

and the charging of services.


experience:

More than fourteen years of experience in international

tax law with a focus on transfer pricing, including

position as tax consultant at PwC and more than ten

years with the global tax department at SAP SE.


transfer pricing:


Degrees and

qualifications:

Julia studied law at the university of Heidelberg and

passed the bar examination in the year 2001.


representations in

groups/committees



related matters:

Active member of various transfer pricing working

groups, including working groups supporting the

cooperation between companies and the tax authorities

(e.g. Arbeitsgemeinschaft für wirtschaftliche Verwaltung

e.V.; Schmalenbach-Gesellschaft für Betriebswirtschaft

e.V.)

BEPS Monitoring Group

(Organisation) name: BEPS Monitoring Group

Acronym: BMG



591762818348-09

Website: https://bepsmonitoringgroup.wordpress.com/

Category: NGO

and more precisely:

Countries/Areas

represented:

International


the organisation:

The BEPS Monitoring Group is a network of tax

researchers and specialists around the world. It was

established in 2013, sponsored by tax justice

organisations, concerned especially with the effects of

international taxation on development.

It now has over thirty members from some twenty

different countries, from Brazil and China to Kenya and

Zambia, and including many EU member states.

Its aim is to produce reports relating to the reform of

the international system for the taxation of

transnational corporations, with a special focus on the

Tax Declaration of the G20 world leaders and the

OECD’s BEPS Action Plan.


represented:

Level of interests

represented:

International

https://www.g20.org/sites/default/files/g20_resources/library/Saint%20Petersburg%20G20%20Leaders%20Declaration%20-%20Tax%20Annex.pdf

http://www.oecd.org/ctp/BEPSActionPlan.pdf


Name and surname: Solomon Picciotto

Nationality: British

Position: Coordinator of the BEPS Monitoring Group

Title: Emeritus Professor, Lancaster University (UK)



transfer pricing:

Professor Picciotto has acted as Coordinator of the BEPS

Monitoring Group since its inception in 2013. He has

helped to write many of its reports, and presented them

at public consultations. He has been following closely

the details of both the G20 BEPS project being carried

out through the OECD, and the development of related

policies and actions in the EU.

He has been coordinating and carrying out research in

the transfer pricing field, focusing especially on the

implications for developing countries, especially through

the International Centre for Tax and Development

http://www.ictd.ac/en.


experience:

Sol Picciotto taught at the Universities of Dar-es-Salaam

and Warwick (Chairman, School of Law), before coming

to Lancaster University (1992-2007, Head of Lancaster

University Law School 1992-5, 2001-4). He was Scientific

Director of the Oñati International Institute for the

Sociology of Law (2009-11), and has been a Visiting

Professor at Nagoya University, Japan, and a Jean

Monnet Fellow at the European University Institute,

Florence. He has been Joint Editor of the International

Journal of the Sociology of Law, and founding Joint

Editor of Social and Legal Studies.


transfer pricing:

Publications on international economic law, international business regulation, state theory and international capital, law and social theory International Business Taxation, Weidenfeld and

Nicolson/Quorum/Cambridge UP (l992), International

Regulatory Competition and Coordination (OUP, 1996),

Regulating Global Corporate Capitalism (Cambridge UP,

2011)

On transfer pricing: "Slicing a Shadow" (1989);

‘International Taxation and Intra-Firm Pricing in

Transnational Corporate Groups’ (1992) Accounting,

Organizations & Society 17(8), pp.759-792; ‘Risky

interstices: transfer pricing and global tax management’

Global Corruption Report. Corruption and the Private

Sector (2009) Transparency International: 70-75; ‘Is the

International Tax System Fit for Purpose, Especially for

Developing Countries?’ (2013) ICTD Working Paper 13;

‘From Independent Entity Back to the Unitary Principle’

(2014) Tax Notes International 73:13-18.


Degrees and

qualifications:

Foundation Scholar, The Manchester Grammar School,

1953-1960. Somerset Thornhill Scholar, Brasenose

College, Oxford, 1960-3. Commonwealth Fellow,

University of Chicago School of Law, 1963-4.

B.A. (Jurisprudence), University of Oxford, 1963, First

Class. J.D. University of Chicago, 1964.


representations in

groups/committees



related matters:

Senior Adviser, Tax Justice Network, 2004-

Coordinator of the International Business Regulation

Forum, a network of academics and non-governmental

organisations, working on international business

regulation issues, 1998-2002.

Member of the Centre Advisory Group, International

Centre for Tax and Development, 2011-

Contributing Author, Tax Analysts, 2013-


Name and surname: Christiana HJI Panayi

Nationality: British and Cypriot

Position: Member of the BEPS Monitoring Group

Title: Dr



transfer pricing:

Senior Lecturer in Tax Law at the Centre for Commercial

Law Studies, Queen Mary, University of London

(teaching International Tax Law, EU Tax Law and

Transfer Pricing)

Research Fellow at the Institute for Fiscal Studies and

the Tax Law Review Committee since 2007

Visiting lecturer in Altium Training Greece


experience:

Visiting Professor at Sorbonne University (Université

Paris 1, 2012-2013) - European Tax Law

Trainee solicitor at Allen & Overy LLP- 2003-2005

(Banking, Tax, Litigation, Private Client, International

Capital Markets, September 2003 - August 2005)

Summer Associate at the London office of Cleary

Gottlieb, Steen & Hamilton LLP, Summer 2001,

Corporate Finance and Tax Departments


transfer pricing:

General publications on international and EU tax law,

but also covering transfer pricing

European Union Corporate Tax Law (Cambridge

University Press, 2013)

Advanced Issues in International and European Tax Law (Hart Publishing, 2015)


Degrees and

qualifications:

Solicitor of England & Wales

Advocate of the Cyprus Supreme Court


representations in

groups/committees



related matters:

Member of the International Network of Tax Research

of the OECD (Steering Group committee member)

Member of the European Association of Tax Law

Professors

Examiner of the Chartered Institute of Taxation

Member of the Examination Sub-Committee of the ADIT

(Advanced Diploma in International Taxation)

Brose Fahrzeugteile GmbH & Co KG

(Organisation) name: Brose Fahrzeugteile GmbH & Co KG

Acronym: Brose



739490419138-37

Website: http://www.brose.com/en/

Category: Corporate

and more precisely:

Countries/Areas

represented:

Germany


the organisation:

Brose is a family owned multinational enterprise with a

successful history of more than 100 years. The company

is a system supplier of the international automotive

industry. The product range comprises mechatronic

systems and drives such as : - Structures and

components for vehicle seats, - Modules and

components for vehicle doors, - Systems for engine

cooling, electric motors and drives. Brose has 58

locations in 23 countries and employed 23,000 people in

2014 with a turnover of more than 5bn. Euro. Brose is

also a very innnovative company.


represented:

Automotive industry

Level of interests

represented:

Germany


Name and surname: Jutta Menninger

Nationality: German

Position: Head of taxes of Brose Group

Title: Dr (PHD)



transfer pricing:

Jutta Menninger is head of taxes of Brose Group, a

family owned multinational enterprise.

She is assistant lecturer at the Federal Academy of

Finance and business commentator for the OECD - WP 6

- Special Session on the Transfer Pricing Aspects of

Intangibles.


experience:

From 2001 to 2014 she was a partner with PwC in

Germany with a focus on Transfer Pricing, Transactions

Valuation & Strategy as well as the valuation of

intellectual property, e.g., brands, patents and licences,

particularly for tax and strategic purposes. She

supported clients in tax audits and tax litigations. She

was seconded to PwC UK from 1997 to 1998.

For more than ten years, she was an assistant lecturer at

two universities and is a member of several technical

committees for the monetary valuation of intangible

assets, e.g. for brand valuation (ISO 10668) and for

patent valuation (DIN 77100).


transfer pricing:

Jutta Menninger is author of numerous publications on

transfer pricing issues as well as on intangible assets. In

her thesis she focused on the "Accounting for Financial

Futures".


Degrees and

qualifications:

Jutta Menninger is a German certified tax advisor and

has studied business economics at the University of

Würzburg.


representations in

groups/committees



related matters:

Member of the IFA (International Fiscal Association)

Member of a tax technical committee of family owned

companies

Member of a tax technical committee of the VDA

(German Association of the Automotive Industry)

Member of the IDW (German Institute of Chartered

Accountants)

Deloitte

(Organisation) name: Deloitte

Acronym: DTTL



70969654430-75

Website: www.deloitte.co.uk

Category: Corporate


Countries/Areas

represented:

International


the organisation:

“Deloitte” is the brand under which tens of thousands

of dedicated professionals in independent firms

throughout the world collaborate to provide audit,

consulting, financial advisory, risk management, tax and

related services to select clients.

Within the framework of its Member firms, Deloitte has

the ability to offer a global, integrated approach to

business issues that combines insight and innovation

from multiple disciplines with a wide range of business

and industry knowledge to help organisations excel

anywhere in the world.

DTTL member firms around the world include

approximately 2,600 transfer pricing professionals that

help companies to manage risks by aligning practical

transfer pricing solutions with their overall business

operations and objectives, assist with strategic

documentation to support their transfer pricing

practices and resolve disputes efficiently.


represented:

Deloitte advices enterprises in numerous sectors

ranging from manufacturing, consumer business,

energy, banking and insurance through life science,

technology and communications and digital economy.

http://www2.deloitte.com/global/en/services/audit.html

http://www2.deloitte.com/global/en/pages/strategy/topics/consulting-deloitte.html

http://www2.deloitte.com/global/en/services/finance.html

http://www2.deloitte.com/global/en/services/risk.html

http://www2.deloitte.com/global/en/services/tax.html

Level of interests

represented:

International


Name and surname: Iwona Georgijew

Nationality: Polish

Position: Tax partner leading Deloitte's transfer pricing practice in

Poland and Central Europe.

Title:



transfer pricing:

Iwona Georgijew is a tax partner leading Deloitte's

transfer pricing practice in Poland and Central Europe

and member of Deloitte's EMEA Transfer Pricing

Leadership.

Iwona advises companies operating in a wide range of industries and on a variety of transfer pricing topics including intra-group policy and documentation, business restructuring, implementation of franchising models and cost sharing arrangements, negotiation and obtaining of Advance Pricing Agreements, transfer pricing risk management projects, controversy and audit defence. Her clients work in various industries including consumer goods, energy, pharmaceutical and e-commerce. She supports countries with emerging transfer pricing rules and with less developed transfer pricing practices with guidance on transfer pricing principles, development of best practices in transfer pricing, workshops for companies and tax authorities. Technically, her interest in transfer pricing includes focus on economic substance and value creation, attribution of profits to PEs and digital economy.


experience:

During more than 20 years of professional career, she

has gained experience and become a leading and

recognized transfer pricing expert. She is a JTPF member

since 2011 and a member of the Tax Consultancy Board

advising the Minister of Finance of Poland.


transfer pricing:

Iwona is a regular speaker on transfer pricing

conferences and seminars in Europe and has published

numerous transfer pricing articles and publications.

Iwona is the co-author of the Polish contribution to the IFA 2014 Report and the reporter to the BNA Series on transfer pricing for Poland.


Degrees and

qualifications:

Warsaw School of Economics - Masters Degree in

Foreign Trade

Academy of Executive Coaching (London) -

Intermediate Diploma in Executive Coaching


representations in

groups/committees



related matters:

Member of Tax Consultancy Board advising the

Minister of Finance of Poland

Member of International Fiscal Association,

contributing to the transfer pricing works of the

Polish IFA branch


Name and surname: Edward Morris


Position: Partner

Title:



transfer pricing:

Partner at Deloitte UK. 18 years transfer pricing

experience in UK Government, EU Commission and

Private Sector. Recognised as top world-wide

International Tax Review TP advisor every year while in

Private Sector.


experience:

HMRC : UK Tax Administration International Section,

Inland Revenue Head Office Grade 6 Senior Principal

Including period where Edward has been Seconded

National Expert to the European Commission (DG

TAXUD, Company taxation initiatives)


transfer pricing:

Published various articles on transfer pricing and

OECD/EU developments, all of which can be found on

the internet.

Contributions on behalf of the Deloitte Global Network

to the OECD consultations on IP, Business Restructuring,

Safe Harbours and TP risk assessment.


Degrees and

qualifications:

1997 - Fully trained Inspector of Taxes Grade 7

Principal (joined Civil Service in 1990 as Fast

Stream Admin Trainee)

1986-1989 - BA Honours at Warwick University in

Medieval and Renaissance History, specialising in

the Northern Italian City States


representations in

groups/committees



related matters:

EUROPEAN ASSOCIATION OF TAX LAW PROFESSORS (EATLP)

(Organisation) name: EUROPEAN ASSOCIATION OF TAX LAW PROFESSORS

(EATLP)

Acronym: EATLP



199090913475-87

Website: www.eatlp.org

Category: Academia

and more precisely:

Countries/Areas

represented:

European


the organisation:

The EATLP was founded in 1999, and is an association

with legal personality under Dutch law. It has its

registered office in Amsterdam.

Among its objectives can be mentioned to contribute to

the development of European tax law and to the

development of research programs on European,

international, domestic and comparative taxation.

The EATLP has since its inception grown to be an

established and well respected academic organization,

having around 300 members from almost all member

states of the European Union as well as from a number

of other countries.


represented:

Level of interests

represented:


Name and surname: Adolfo Martin Jimenez

Nationality: Spanish

Position: Professor of Tax Law ("Catedrático de Derecho

Financiero"), University of Cádiz, Spain

Title: Prof.



transfer pricing:

Full Professor of Tax Law ("Catedrático de Derecho

Financiero"), University of Cádiz, Spain, since July 2009.

Jean Monnet Chair EU Tax Law, awarded by the EU Commission in 2014. Director of the Master of Taxation, University of Cádiz

(from 1st' 2008-2009, to 6th edition, 2014-2015)

Research activity exclusively focused on EU and

international tax law, including very relevant work on

transfer pricing issues. Teaching activity, University of

Cádiz, on domestic, international and EU tax law

(including transfer pricing). Director of several research

projects (EU and international tax law).


experience:

Adolfo has been a visiting professor / guest lecturer at

other Spanish and foreign universities and often

participates in conferences on international and EU tax

law, including transfer pricing issues, in Spain and

abroad (Europe, Asia and South America). He frequently

conducts teaching and lecturing activities for and with

tax inspectors and public officials.

Adolfo also has a broad experience, as independent

expert, in consultancy projects or participation in

advisory committees for public entities at national and

international level and in doing of-counselling work for

private entities on international and EU tax law.


transfer pricing:

Books: A. Martín Jiménez & J. Calderon Carrero, Los precios de

transferencia en la encrucijada del siglo XXI ("Transfer

Pricing at the Cross-roads in the XXTst Century") A

Coruna: Net Biblo

Carmona, Calderon, Jones, Martín, Pérez-Rodilla, Trapé,

Fiscalidad de las operacione vinculadas ("Taxation of

Transactions between Associated Companies"), Valencia,

Ciss, 2009

Several Articles


Degrees and

qualifications:

- Ph.D ('with distinction') European University Institute,

Florence, Italy, 1997 ("An institutional comparative

analysis of corporate taxation in the European

Community", published in 1999 by Kluwer).

- LL.M, University of Wisconsin-Madison, U.S. (1995).

- Law degree, 1992, University of Cádiz (with honours:

best regional and university academic record in the field

of social sciences and humanities)


representations in

groups/committees



related matters:


Name and surname: Georg W. Kofler

Nationality: Austrian

Position: Professor

Title: Professor of Tax Law at Johannes Kepler University of

Linz, Austria



transfer pricing:

Professor of Tax Law at Johannes Kepler University of

Linz, Austria

Georg is part of formal and informal research networks

and, e.g., serves as a member of the faculties of several

postgraduate programs, as a member of the D-A-CH tax

committee, as head of the working group on EU law of

the Scientific Board of the Austrian Chamber of Tax

Advisors, as a deputy member of the CFE and as

chairman of CFE's ECJ Task Force; he also was a member

of the Austrian government's most recent tax reform

commission.


experience:

Before joining the University of Linz, Georg has worked

with the International Department of the Austrian

Federal Ministry of Finance (2002-2003, 2009), as an

Assistant Professor at the University of Linz (2001-2006)

and as an Acting Assistant Professor of Tax Law at New

York University School of Law (2006-2008).

Georg has worked in the field of taxation, especially

European and International taxation, for more than 15

years and is involved in tax research, training and

education at institutions mostly in Europe and the

United States.


transfer pricing:

Georg has published and lectured widely on issues of

Austrian, International and European taxation. Recent

research includes an in-depth analysis of tax treaty

aspects of transfer pricing (G. Kofler, "Article 9

(Associated Enterprises)", in: E. Reimer & A. Rust (eds),

Klaus Vogel on Double Taxation Conventions, Kluwer

2015, 128 pp.) as well as contributions on transfer

pricing within the OECD's BEPS project (G. Kofler, "BEPS

and Transfer Pricing: The Arm's Length Standard under

Pressure?" BTR 2013, pp. 646-665) and the EU's

Arbitration Convention (G. Kofler, "Resolving Tax

Disputes: The EU Arbitration Convention", in: E.

Baistrocchi (ed.), Resolving Tax Treaty Disputes: A Global

Analysis, Cambridge University Press 2015 [in print]).


Degrees and

qualifications:

Georg has earned a doctorate in law as well as a

doctorate in business administration in 2002 and 2003

respectively and an LL.M. in International Taxation from

New York University in 2004. In 2006 he has gained his

postdoctoral lecturing qualification ("Habilitation") with

a thesis on "Double Taxation Conventions and European

Community Law".


representations in

groups/committees



related matters:

European Network on Debt and Development (Eurodad)

(Organisation) name: European Network on Debt and Development

(Eurodad)

Acronym: Eurodad



09136982496-09

Website: www.eurodad.org

Category: NGO

and more precisely:

Countries/Areas

represented:

International


the organisation:

Eurodad is a network of 47 non-governmental organisations (NGOs) from 19 European countries working on issues related to debt, development finance and poverty reduction. Eurodad’s aims are to: - Push for development policies that support pro-poor and democratically-defined sustainable development strategies;

- Support the empowerment of Southern people to chart their own path towards development and ending poverty;

- Seek a lasting and sustainable solution to the debt crisis, appropriate development financing, and a stable international financial system conducive to development. Taxation is an essential source of financing for development and tax justice is therefore a key focus area for Eurodad.


represented:

Level of interests

represented:


Name and surname: Tove Maria Ryding

Nationality: Danish

Position: Policy and Advocacy Manager - Tax Justice

Title:



transfer pricing:

Policy and Advocacy Manager - Tax Justice

Elected as one of two representatives of Europe in the

Coordinating Committee of the Global Alliance for Tax

Justice, and coordinator of the campaign and policy

group of the Alliance.

Policy coordination on tax and transparency related

issues among Eurodad members and allies across

Europe.

Followed the work of the UN Expert Committee on

International Cooperation in Tax Maters closely since

2013.


experience:

Until 2013: Senior Policy Analyst and Policy Officer - Tax Justice

2011-2013: Greenpeace: Climate Policy Coordinator

2008-2009: CARE International –Climate Change Advocacy Coordinator

Also, coordinated and co-authored the report "Giving With One Hand - Taking With the Other - Europe's Role in Tax Related Capital-Flight from Developing Countries" (Eurodad, 2013), and co-authored the follow-up report "Hidden Profits" (Eurodad, 2014). These reports examine a number of transparency and tax related cases, laws and regulations (including relating to harmful tax practices and transfer pricing) in over 10 different EU member states.


transfer pricing:


Degrees and

qualifications:

Biology (B.Sc), University of Copenhagen. Additional

courses: Natural Resource Politics and Economics;

Environmental Economics - University of Copenhagen.


representations in

groups/committees



related matters:


Name and surname: Hernán Cortés Saenz


Position: Policy Analyst - Tax Justice

Title:



transfer pricing:

From 2014 (July): Policy Analyst - Tax Justice

Background research for the Eurodad report "Fifty

shades of Tax Dodging: the EU's role on supporting an

unjust global tax system" (Eurodad, 2015).


experience:

Overseas Development Institute – Research assistant (March 2014 – July 2014) Initiative for Policy Dialogue University of Columbia and Friedrich-Ebert-Stiftung New York – Research Assistant (June 2013 - December 2013) World Forum of Civil Society Networks – UBUNTU – Policy Officer (September 2009 – June 2013)


transfer pricing:


Degrees and

qualifications:

PhD in International Relations, Universitat Autònoma de Barcelona Masters in International Relations, Universitat

Autònoma de Barcelona


representations in

groups/committees



related matters:

Member of the International and European committee

in favor of the Financial Transaction Tax, leading

advocacy in Spain and at the European level when

linked to Spanish representatives.

Financial Transparency Coalition

(Organisation) name: Financial Transparency Coalition

Acronym: FTC



455124911857-71

Website: http://financialtransparency.org/

Category: NGO

and more precisely:

Countries/Areas

represented:

International


the organisation:

The Financial Transparency Coalition (FTC) is a global network of more than 150 allied civil society organizations, more than a dozen governments, and some of the world’s foremost experts on illegal movements of capital from one country to another, known as illicit financial flows (IFFs). The FTC uses its wide reach and deep expertise to influence global norms and standards for financial transparency, and promote a transparent, accountable and sustainable financial system that works for everyone.

The civil society organizations in FTC coordinating

committee include Eurodad (Belgium), Transparency

International (Germany), Tax Justice Network (United

Kingdom), Christian Aid (UK), Global Witness (UK), the

Centre for Budget and Governance Accountability

(India), Latindadd (Peru), Tax Justice Network-Africa

(Kenya), and Global Financial Integrity (United States).

The government members of FTC Partnership Panel

include officials from Belgium, Denmark, Finland,

France, Germany, Greece, the Netherlands, Norway,

Spain, Canada, Chile, India, Peru and South Africa.


represented:

Level of interests

represented:


Name and surname: Koen Roovers

Nationality: Dutch

Position: European Union lead advocate for the Financial

Transparency Coalition

Title:



transfer pricing:

European Union lead advocate for the Financial

Transparency Coalition

Based in Brussels, Belgium, Koen

- leads EU advocacy on an influential advocacy campaign

to curb illicit financial flows, a major part of which

relates to trade mispricing.

- carries out advocacy towards the EU institutions, and

OECD, to inform the crafting of measures that enhance

corporate transparency, including country-by-country

reporting about where transnational corporations

employ people, have subsidiaries, declare profits, or pay

taxes, among other vital information for oversight

organisations.

- facilitates the development of Coalition policy on illicit

financial flows, especially in the European Union context


experience:

Koen has worked previously for civil society

organisations advocating for greater transparency in EU

decision-making processes. He has also assisted a

member of the European Parliament as Policy advisor

for several years. Prior and during this employment,

Koen worked on advocacy and community projects in

South-Asia and West-Africa.


transfer pricing:


Degrees and

qualifications:

Rijksuniversiteit Groningen (University of Groningen,

The Netherlands) - Bachelor/Master's degree in

International Organisations and International Relations.


representations in

groups/committees



related matters:

Koen is a member of the European Commission’s Expert

Group on Automatic Exchange of Financial Account

Information1 for Direct Taxation Purposes (AEFI Group)


Name and surname: Alex Cobham


Position: Director of Research, Tax Justice Network

Title:



transfer pricing:

Director of Research, Tax Justice Network


experience:

Alex has held various policy and research posts as an

economist over the last fifteen years,, including as a

research fellow at the Center for Global Development,

as chief policy adviser at Christian Aid and head of

research at Save the Children (UK), and at Oxford as a

junior economics fellow at St Anne’s college, Oxford and

as a researcher at Queen Elizabeth House (Department

of International Development, Oxford University). He

has also consulted widely, including for the UK

government and the World Bank. Further details at

http://uncounted.org/contact.


transfer pricing:

'International distribution of the corporate tax base:

Implications of different apportionment factors under

unitary taxation', International Centre for Tax and

Development Working Paper 27 (with Simon Loretz)

http://uncounted.org/contact

Tax havens and illicit flows', pp.337-372 in P. Reuter

(ed.), Draining Development: Controlling Flows of Illicit

Funds from Developing Countries, Washington, DC:

World Bank.


Degrees and

qualifications:

MSc International Economics, Banking & Finance

(Distinction), 1997-1998 Cardiff Business School,

University of Wales.

MA (Hons) Economics (Upper Second), 1993-1997 Univ.

of Edinburgh.


representations in

groups/committees



related matters:

Preparatory group member: International Commission

for the Reform of International Corporate Taxation

(ICRICT)

Technical advisory group member: Fair Tax Mark

Trustee: ActionAid UK

GRANT THORNTON Société d'Avocats

(Organisation) name: GRANT THORNTON Société d'Avocats

Acronym: Member of Grant Thornton International Ltd



787497318680-06

Website: www.avocats-gt.com

Category: Partnership


Countries/Areas

represented:

International


the organisation:

GT Société d’Avocats is a tax and legal attorney firm.

Grant Thornton International, the network of which it is

a member also performs accountancy services, audit

and specialist and operational advisory services.


represented:

Level of interests

represented:

Worldwide, European and national. Our clients range

from SMEs to large MNEs.


Name and surname: Chaïd Dali-Ali

Nationality: French

Position: Attorney at Law, Transfer Pricing Partner

Title: Maître



transfer pricing:

Transfer Pricing partner


experience:

Chaïd has more than 15 years of experience in transfer

pricing from his former activities with the French Tax

Administration and the OECD, as well as in advising

multinational enterprises in numerous industries in

North America and in France.

When he was with both, the French Tax administration

and the OECD, he had the opportunity to conduct

training TP programs for foreign tax administrations

(Eastern Europe countries through Fiscalis, Argentina

and Chile).


transfer pricing:

“Cross-border Intragroup Services: back to basics”,

October 2, 2010, Tax Management Transfer Pricing

Report, Bureau of National Affairs, Washington D.C.

("BNA")

“OECD Draft on Transactional Profit Methods: Business

Realities”, March 13, 2008, BNA;

“OECD Restructurings Draft: On the Right Track to

Achieve OECD Objectives?”, November 6, 2008, BNA;

« Les Administrations fiscales face aux Multinationales:

des divergences substantielles mais un accroissement

exponentiel de leur coopération », Option Finance,

France, November 2010

« Réorganisations d’entreprises : une liberté surveillée»,

Option Finance, France, Mai 2010;

« Prix de transfert : une évolution de l'environnement

réglementaire empreinte de suspicion ?", Option

Finance, France, Avril 2014


Degrees and

qualifications:

Attorney at Law at the Paris Bar;

Master in Tax Law: National School of Tax; and

Bachelor of Business Law: University of Paris


representations in

groups/committees



related matters:


Name and surname: Wendy Nicholls


Position: Transfer Pricing Partner

Title: Partner



transfer pricing:

Wendy leads Grant Thornton transfer pricing practice in

London. Wendy has over 25 years international tax

experience advising clients in the UK and overseas and

helps clients plan, implement, document and defend

their transfer pricing policies in a practical and

pragmatic way.


experience:

Prior to joining Grant Thornton in October 2009, she was

a partner in a 'big 4' firm, responsible for transfer pricing

for the South of England. She has also worked overseas

and has acted an expert witness in the field of transfer

pricing.


transfer pricing:

Regular author of articles on transfer pricing topics in

the professional press. contributing author to Tolley's

UK transfer pricing 2012-13


Degrees and

qualifications:

FCA (Fellow member of the Institute of Chartered

Accountants in England and Wales)

CTA (Chartered Institute of Taxation)

BSc (Hons) University of Southampton


representations in

groups/committees



related matters:

Tax committee of BIAC

International Tax Center Leiden (Transfer Pricing Research Center)

(Organisation) name: International Tax Center Leiden (Transfer Pricing

Research Center)

Acronym: ITC Leiden



437211919229-70

Website: http://www.itc-leiden.nl/

Category: Academia

and more precisely:

Countries/Areas

represented:

International


the organisation:

ITC Leiden is specialized in advanced studies and

research in international taxation. It offers numerous

courses and conferences on international tax law,

including a 'Master in Advanced Studies in International

Tax Law' and a full-time one-year programme 'Adv. LLM

in EU Tax Law'. ITC Leiden also publishes books,

including the widely-used 'Materials on international,

Transfer Pricing and EU Tax Law'.

ITC Leiden has established the Transfer Pricing Research

Center to examine transfer pricing issues and monitor

practices in this area, with the aim of assisting MNEs and

governments to deal more effectively with the

increasing complexity in this area.


represented:

Level of interests

represented:


Name and surname: Stefano Simontacchi

Nationality: Italian

Position: Director of the Transfer Pricing Research Center Leiden

Title: Dr



transfer pricing:

Stefano is an economist with a LL.M. in International

Taxation and his practice focuses on tax law, with

particular emphasis on real estate transactions, real-

estate and equity funds, private equity, M&A and

reorganisations, transfer pricing, and fiscal planning.

He has extensive expertise in APAs and Dispute

resolution (EU Arbitration convention).

Stefano is the managing partner of the Italian law firm

Bonelli Erede Pappalardo.

He is Director of the Transfer Pricing Research Center

Leiden


experience:


transfer pricing:

The Cost Plus Method: Determination of the Margin and

Cost Base, in International Transfer Pricing Journal,

1999, at 86 et seq.

Profili tributari dei prezzi di trasferimento, in AA.W., I

prezzi di trasferimento, determinanti e metodologie di

calcolo, Egea, 2002

Transfer Pricing between Italy and China, in E. Toti

(edited by), Italy Taw, Giappichelli, 2010

The Impact of the Recent Economic Downturn on

Transfer Pricing: an Opportunity to Analyse the

Comparability Factor of Economic Circumstances and the

Related Use of Multiple Year

Data, in AA.W.2011, Derecho Fiscal International -

temas selectos, Editorial Porrua, 2011

Il valore normale nella determinazione dei prezzi di

trasferimento intercompany, in AA.W., Valore in dogana

e transfer pricing, IPSOA Wolters Kluwer, 2013


Degrees and

qualifications:

International Taxation PhD: Faculty of Law of Leiden

University, supervisor: Prof. Kees van Raad (2007)

International Taxation LLM (Hons): Leiden University

(2000)

Chartered accountant (1998)

BA (Hons), specialisation in law and accounting, from L.

Bocconi University (1995)


representations in

groups/committees



related matters:

A.P. Moller Maersk

(Organisation) name: A.P. Moller Maersk

Acronym: Maersk



680443918500-51

Website: www.maersk.com

Category: Corporate

and more precisely:

Countries/Areas

represented:

Denmark


the organisation:

A.P. Moller – Maersk is the holding company of the

Maersk Group, a worldwide conglomerate that operates

in some 130 countries with a workforce of over 89,000

employees. In addition to owning one of the world’s

largest shipping companies, Maersk is involved in a wide

range of activities in the shipping, logistics, and the oil

and gas industries. The Maersk Group has five core

businesses which include Maersk Line, APM Terminals,

Maersk Oil, Maersk Drilling and APM Shipping Services.

The last business area is comprised of Maersk Supply

Service, Maersk Tankers, Damco and Svitzer. In 2014 the

group had a turnover of USD 47.6 billion


represented:

Industry

Level of interests

represented:


Name and surname: Mark-Jan van der Torre

Nationality: Dutch

Position: Global Head of Transfer Pricing at Maersk Group,

Denmark

Title: Mr (Master of Law)



transfer pricing:

International transfer pricing and tax specialist with 20

years of relevant experience from Big 4 consultancy,

Government/Revenue and in house transfer pricing

management. Mark-Jan's experience covers both

strategic and operational work, including international

tax strategies, complex transfer pricing structures, risk

management/ control and tax controversy.

Mark-Jan's is accountable for global transfer pricing in

the Maersk Group and main responsibilities cover the

group transfer pricing strategy, transfer pricing risk

management, processes and procedures (including MAP/

APA), technical assessment and advice on complex

business projects, leading the group transfer pricing

team and coordination of transfer pricing

documentation and compliance.


experience:

Former competent authority member of the

Netherlands (MAP and APA), delegate to OECD Working

Party No.6 and member of the EU Joint Transfer Pricing

Forum.


transfer pricing:

Co author of 'The profit sharing mechanism of the

CCCTB', MBB 2008-11


Degrees and

qualifications:

Postgraduate course European Fiscal Studies (EFS),

Erasmus University in Rotterdam

Economics of Transfer Pricing, Dutch Revenue Service

Master in Tax Law (LL.M), Leiden University


representations in

groups/committees



related matters:

Member of Tax Executive Institute (TEI)

NERA Economic Consulting

(Organisation) name: NERA Economic Consulting

Acronym: NERA



425869918343-68

Website: http://www.nera.com/practice-areas/transfer-

pricing.html

Category: Corporate


Countries/Areas

represented:

International


the organisation:

NERA Economic Consulting is a global firm of experts

dedicated to applying economic, finance, and

quantitative principles to complex business and legal

challenges. For over half a century, NERA's economists

have been creating strategies, studies, reports, expert

testimony, and policy recommendations for government

authorities and the world’s leading law firms and

corporations. NERA brings academic rigor, objectivity,

and real world industry experience to bear on issues

arising from competition, regulation, public policy,

strategy, finance, and litigation.

At NERA’s core is an exceptional team of many of the

world’s leading experts in numerous industries and key

disciplines, all sharing a passion for economics and a

commitment to integrity and independence” (Dr.

Lawrence Wu, NERA’s President).


represented:


Name and surname: Emmanuel Llinares

Nationality: French

Position: Senior Vice President, Chair of NERA's Global Transfer

Pricing Practice by NERA Economic Consulting

Title: Dr



transfer pricing:

Dr. Llinares is an economist specializing in intercompany

pricing, valuation, and intellectual property analyses. For

a number of years, he has advised multinational

companies on defining and implementing their intra-

group pricing policies, valuing assets including in

particular intellectual property. He has assisted them on

issues ranging from re-structuring to pricing design and

negotiations with tax authorities and provided support

in the context of litigation.

Dr. Llinares has managed scores of large valuation and

intercompany pricing projects for multinationals in a

wide range of industries, including transportation,

cosmetics and luxury goods, financial services, chemical

industry and various other sectors. He has been involved

in negotiation and preparation of several Advance

Pricing Agreements. He has also managed the economic

analyses aspects of a large number of tax-related audits

in Europe and other regions.


experience:

Prior to joining NERA, Dr. Llinares was an economist

with Arthur Andersen's in London and with the KPMG

Tax network in Paris. Dr. Llinares is a former lecturer at

the Economics Department of the University of

Delaware and at the Ecole Supérieure de Gestion, a

business school in Paris.


transfer pricing:

BEPS Action 8, 9 and 10: Discussion Draft on Revisions to

Chapter I of the Transfer Pricing Guidelines, Feb 2015

Discussion Draft on BEPS Action 10: Use of Profit Split in

the Context of Global Value Chains, Feb 2015 BEPS

Action 10:

Discussion Draft on the Transfer Pricing Aspects of

Commodity Transactions, Feb 2015

Value Creation, Comparability and Bargaining Analysis:

Key References in Transfer Pricing Going Forward, May

2014 NERA's

Comments on the OECD's Discussion Draft on Transfer

Pricing Documentation and Country-by-Country

Reporting, Feb 2014 NERA's Comments on the OECD's

Revised

Discussion Draft on Transfer Pricing Aspects of

Intangibles, Oct 2013

Prix de transfert: un levier de création de valeur et de

compétitivité encore méconnu des dirigeants,

(Transferpricing - An enabler for competitiveness often

undermined by managers) Jan 2012

The Tax Department's Role in Sustainable Transfer

Pricing, International Tax Review, Dec 2012

Intangible Assets Valuation and High Uncertainty,

International Tax Review, Aug 2011


Degrees and

qualifications:

Dr. Llinares has a PhD in economics from the University

of Delaware and a doctorate in economics from the

University of Lyon.


representations in

groups/committees



related matters:


Name and surname: Sébastien Gonnet

Nationality: French

Position: Vice President in the Global Transfer Pricing Practice at

NERA Economic Consulting.

Title:



transfer pricing:

Based in Paris, Mr. Gonnet specializes in the areas of transfer pricing, intellectual property, and valuation. For a number of years, he has advised multinational companies in transfer pricing system design and implementation, business restructurings, and intellectual property and business valuation primarily in Europe, but also in China, in a range of industries. He also acts as an expert economist in advance pricing agreements and tax audits in Europe and China.

Mr. Gonnet is a frequent lecturer and has authored many publications on the economics of transfer pricing. He is also a frequent speaker at transfer pricing, intellectual property, and valuation conferences and training workshops, and has presented to tax authorities in Europe and China.


experience:

Before joining NERA Economic Consulting, Mr. Gonnet

was an economist at KPMG.


transfer pricing:

Nov 2014 Understanding Risks in the Enterprise : The Key

to Transfer Pricing for Today's Business Models IBFD

Jan 2014 Value Creation, Comparability and Bargaining

Analysis: Key References in Transfer Pricing going

forward NERA book

April 2013 Comparability Adjustments in the Absence of Suitable Local Comparables in Emerging and Developing Economies BNAI Transfer Pricing International Journal

Oct 2011 Location Specific Advantages —China BNAI

Transfer Pricing International Journal

July 2011 Location Specific Advantages —Case Studies

BNAI Transfer Pricing International

May 2011 Location Specific Advantages —Principles BNAI Transfer Pricing International Journal

Mar 2010 The State of the Art in Comparability for

Transfer Pricing IBFD International Transfer

Pricing Journal

Dec 2008 Transfer Prices Determined by Game Theory:

BNAI Tax Planning International Transfer Pricing

Dec 2007 Contribution Analyses Under the Profit Split

Method International Tax Review's Intellectual

Property 6th Edition


Degrees and

qualifications:

Mr Gonnet holds a master of science in management from HEC, Paris (Ecole des Hautes Etudes Commerciales) and a master of science in international taxation from Paris II Law University.


representations in

groups/committees



related matters:

Network member Firms to PwC

(Organisation) name: Network member Firms to PwC

Acronym: PwC



60402754518-05

Website: http://www.pwc.com/

Category: Corporate


Countries/Areas

represented:

International


the organisation:

PwC is a leading professional services Firm. PwC’s

Transfer Pricing Services practice has a global

geographical footprint and can draw from the expertise

and experience of over 3.000 full time TP experts.


represented:

Level of interests

represented:


Name and surname: Isabel Verlinden

Nationality: Belgian

Position: PwC’s Global Head of Transfer Pricing

Partner International Tax and Transfer Pricing – PwC

Brussels

Title:



transfer pricing:

Isabel Verlinden is heading up PwC’s Global Transfer

Pricing practice covering 157 countries.

She assists leading companies in a vast array of

industries with the design and implementation of

sustainable tax strategies. A fair intercompany pricing

policy is often accompanied by ensuring upfront

certainty through Advance Pricing Agreements. In the

absence of upfront assurance, the search for effective

means to alleviate double taxation forms part of her

day-to-day practice as well.


experience:

She gathered first-hand knowledge of the Transfer

Pricing challenges faced by companies operating across

the globe based on over 25 years of experience working

for PwC (and its legacy Firms) in Brussels and

Washington, DC.


transfer pricing:

She is an active writer for international tax and business

periodicals. She has (co-) authored close to 100 articles

and books to date (including PwC’s “Mastering the IP

Life Cycle” and PwC’s “Substance 2.0: Aligning

International Tax Planning with Today’s Business

Realities”).


Degrees and

qualifications:

Degree in Commercial and Financial Economics, Major in

Accountancy, University of Brussels, 1991 (Thesis

received BDO Award 1991)

Degree in Commercial and Fiscal sciences, Major in

Taxation, University of Brussels, 1988 (Thesis received

BDO Award 1988)

Degree in Applied Economics, Major in International

Business Affairs, University of Louvain, 1986


representations in

groups/committees



related matters:

Isabel is a member of the International Fiscal

Administration (where she is regularly solicited to

present), represents PwC on Transfer Pricing related

matters vis-à-vis the OECD and is a recognized Belgian

tax expert (IAB).


Name and surname: Ionut Simion

Nationality: Romanian

Position: Country Managing Partner for PwC Romania.

PwC’s Leader of Central Eastern Europe transfer pricing

network

Partner International Tax and Transfer Pricing – PwC

Bucharest

Title: PhD in Economics



transfer pricing:

Ionuţ heads the Romanian transfer pricing practice and

is the leader of the CEE Transfer Pricing Network.

Ionut has extensive experience in the preparation and

negotiation of APAs, binding ruling requests and the

management of transfer pricing disputes. He has

negotiated all APAs issued to date by the Romanian Tax

Administration and closed numerous transfer pricing

cases with no adjustments.

Ionut is constantly involved in discussions with the

Romanian Ministry of Finance with the intention of

updating Romanian tax legislation and is a member

assistant of the EU Joint Transfer Pricing Forum since

2008. In this capacity he has actively contributed to the

preparation and implementation in Romania of the

legislation governing transfer prices and advance pricing

arrangements.

Ionut has been actively involved in the modernisation of

the transfer pricing legislation of various CEE states such

as: Bulgaria, Serbia, Croatia, and Albania.


experience:

Ionut joined PwC Bucharest in October 2000, after

spending seven years in the retail and consumer

industry, where he last acted as Finance Director. He has

extensive experience in telecommunication,

automotive, the retail and consumer industries.

Ionuţ has gained considerable experience working on

national and international assignments, including a six-

month secondment to the PwC New York office,

assisting companies in the implementation of value

chain transformation projects, design of international

corporate structures and transfer pricing defence

policies, as well as being actively involved in real estate

and merger & acquisition projects.


transfer pricing:

Transfer Pricing International Journal, Cahiers de droit

fiscal international, International Transfer Pricing Book;


Degrees and

qualifications:

Degree in Finance & Accounting, Academy of Economic

Studies, Bucharest, 1993

PhD in Economics, Academy of Economic Studies,

Bucharest, 2002


representations in

groups/committees



related matters:

Ionut is Vicepresident of Amcham(Romania), Chairman

of its Tax Committee and since January 2015, Leader of

Finance & Taxation Task Force within the Coalitia pentru

Dezvoltarea Romaniei. He is also a board member of the

Romanian American Foundation (RAF) and member of

the Romanian Chamber of Tax Advisors (CCF).

PLANSEE GROUP

(Organisation) name: Plansee Group

Acronym: Plansee



171448418631-80

Website: http://www.plansee-group.com

Category: Corporate

and more precisely:

Countries/Areas

represented:

Austria


the organisation:

The Plansee Group is an international high-tech

company based in Reutte, Austria and is one of the

world's leading suppliers of Molybdenum and Tungsten -

from powder production through powder-metallurgical

processes. Plansee Group customers operate in a variety

of advanced industries including automotive, energy,

electronics, semiconductors and medical engineering.

Plansee Group employs around 6,000 people with

production & sales companies in 50 countries; Plansee

Group has presence in more than 10 European

Countries. Plansee-Group deals with a complex supply

chain and also financial and intra group services

transactions.


represented:

Metallurgical Industry. Molybdenum and tungsten-

metallurgical processes customized processing and

recycling.

Level of interests

represented:


Name and surname: Brigitte Baumgartner

Nationality: Austrian

Position: International Tax

Title: LL.M., P LL.M.



transfer pricing:

Responsible for international tax matters special focus

on implementing and monitoring the transfer pricing

policy and documentation world-wide for Plansee Group

- Has implemented planning and monitoring processes

for the group performs risk analysis and sets the transfer

pricing policy for each division within the group

- Coordinates monitoring process during the year and

year- end adjustments

- Responsible for drafting and reviewing IC Agreements

from a transfer pricing perspective, analysis and review

of Cost Contribution Arrangements within the group

- Provides support to legal entities for international tax

matters with a special focus on transfer pricing audits.

- Has coordinated audits in Italy, Czech Republic,

Germany, Taiwan, United States and India.


experience:

Before Joining Plansee Group, Brigitte worked in the

Special Projects Office of the Department of Treasury

and Public Finance in Mexico (Treaty Negotiations by the

Ministry of Finance) Participated in transfer pricing

forums of international organisations such as the OECD.

Brigitte also worked as Financial Institution auditor for

the tax administration service in Mexico.


transfer pricing:


Degrees and

qualifications:

Johannes Kepler University, Linz Austria, P LL.M. in

European Tax Law

Temple University Beasley School of Law, Philadelphia

USA, LL.M. with Certificate in Tax Law

Instituto Tecnológico Autónomo de México (ITAM),

Mexico City, Post Graduated Diploma In Mexican Tax

Law and Bachelor of Laws


representations in

groups/committees



related matters:

PRYSMIAN GROUP

(Organisation) name: Prysmian Group

Acronym: Prysmian



974253816995-48

Website: www.prysmiangroup.com

Category: Corporate

and more precisely:

Countries/Areas

represented:

Italy


the organisation:

The Prysmian Group is the world leader in the energy

and telecom cables and systems industry with over €7

billion in sales in 2014, approximately 19,000 employees

in 50 countries, and 89 production sites. The Group has

17 Research & Development centres in Europe, USA,

South America and China. Prysmian S.p.A. is the largest

Italian Public Company.


represented:

Level of interests

represented:

http://www.prysmiangroup.com/


Name and surname: Laura Beretta


Position: Group Tax Director, Prysmian S.p.A.

Title:



transfer pricing:

Group Tax Director

- Coordination of a tax team involved mainly in cross-border tax issues, M&A and transfer pricing.

- Direct involvement in the restructuring/integration processes following external acquisitions, including harmonisation of transfer pricing policies.

- Involvement in tax compliance strategy and controversies around the world and coordination of cross-border tax issues and extraordinary matters relating to 50 countries.

- Direct involvement in transfer pricing compliance and documentation strategy and implementation, and in any transfer pricing controversies that may arise in different countries.


experience:

Group tax director of an Italian multinational group. Coordinating a Tax Team mainly involved in Cross border tax issues. Managed also all transfer pricing related matters, including definition of policies, documentation, implementation of intra-group pricing and Advanced Pricing Agreements on both tangible and intangible services. International tax advisor in international professional service firms. Managed corporate national and international tax law with specialisation in strategic tax planning, corporate restructuring, and mergers and acquisitions. Assisted, as an external advisor, several Italian multinational groups operating in the European Union.


transfer pricing:


Degrees and

qualifications:

1997 - Charted Accountant qualification

1994 - Qualified Tax Advisor qualification

1994 - University of Milan "Bocconi" - Degree in

Economics and Business Administration


representations in

groups/committees



related matters:

Member of the International Fiscal Association (IFA),

Italian branch

Member of the International Taxation Committee within

Confindustria (the Italian association of industries)

Member of the Corporate Tax Director Italian

Association (AFI)


Name and surname: Gianni De Robertis


Position: Chief Economist of KPMG Studio Associato in Italy and

Partner of KPMG Advisory

Title:



transfer pricing:

Gianni is an economist and has provided transfer pricing

assistance for more than fifteen years to multinational

companies as well as SMEs operating in the EU, on the

economic, fiscal and management aspects of intra-group

transactions. His areas of interest also include business,

financial and economic analysis, supply chain and value

chain analysis, international trade, and foreign

investments.


experience:

Prior to working in Italy, Gianni worked as a senior

transfer pricing economist with KPMG in the UK and

Fidal in France. He has been a consultant, on

secondment, to the OECD (Organisation for Economic

Co-operation and Development) Transfer Pricing Unit.

Gianni has managed a wide range of transfer pricing

assignments, covering both fiscal and management

aspects of transfer pricing including: preparation of

studies and documentation, economic and

benchmarking analysis, analysis of transactions of

goods, services and intangible property, royalties

analysis, cost contribution arrangements, bilateral and

unilateral Advance Pricing Agreements (APAs) and

Mutual Agreement Procedures (MAPs).


transfer pricing:

“Reacting to the crisis – Can we support loss split”,

Cheng Chi, G. De Robertis, Atsuko Kamen and Hiroyuki

Takahaski in “Planning for recovery – examining transfer

pricing in the current environment and beyond”, KPMG

Publication n. 909-008, September 2009.

“Treatment of R&D expenses in Italy”, Gianni De

Robertis and Maria Eugenia Palombo, in “Comparative

Survey: Tax Treatment of R&D expenses”, Eduard

Sporken and Edwin Gommers, International Transfer

Pricing Journal, IBFD, January/February 2007

Transfer Pricing and Intangibles in Italy”, D. Busetto, G.

De Robertis, Cahiers de Droits Fiscal International,

Volume 92a, 2007

“Business reorganization and exit charges”, G. De

Robertis, M. Kaut, D. Preshaw, International Tax Review,

n. 28, 2006

“Using comparables with significant intercompany

sales”, P. Balkus, G. De Robertis and C. North,

International Tax Review, n. 23, 2005

"European integration and internal economic

geography: the case of the Italian manufacturing

industry 1971-1991", Gianni De Robertis, International

Trade Journal, August 2001


Degrees and

qualifications:

London School of Economics, London (UK)- Master's in

Economics

University of Ancona (Italy) - Degree in Economics and

Business

Ecole de commerce de Dijon (France) - European

Business Certificate – diploma in advanced international

business studies


representations in

groups/committees



related matters:

Member of the American Economic Association

Member of the National Association of Business

Economists

Member of the International Fiscal Association (IFA),

Italian branch

REPSOL GROUP

(Organisation) name: Repsol, S.A.

Acronym: Repsol



69240395197-02

Website: http://www.repsol.com/

Category: Corporate

and more precisely:

Countries/Areas

represented:

Spain


the organisation:

Repsol is a Spanish energy multinational company,

integrated and global, with a vast experience in the

area, that carries out upstream (oil and gas exploration

and production) and downstream (transportation,

refining, chemicals, marketing and liquid petroleum gas)

activities. Repsoľs activities in Spain go back to 1927,

although Repsol, as we know it today, came into being in

1987. In October of that year, Repsol was created as the

result of the reorganization of the Spanish oil sector and

adaptation to worldwide change. Nowadays, the Group

has presence in the five continents with subsidiaries all

around the world in more than 30 countries.

Particularly, the Group has presence in Southern

Europe, through downstream activity, especially in

Mediterranean countries such as Spain, Portugal and

Italy. Also in the UK.


represented:

Industry

Level of interests

represented:

Non-governmental member

http://www.repsol.com/


Name and surname: Miss Rocío Bermúdez Becerra


Position: Transfer Pricing Manager

Title:



transfer pricing:

Responsible in Repsol Group for setting up the transfer

pricing policies across the Group. Involved in the

preparation of transfer pricing documentation,

providing support in tax audits, dealing with tax

authorities in different countries, APA negotiations,

providing technical advice to new intercompany

transactions.


experience:

Previous experience in a Big Four Firm as Transfer

pricing consultant with focus on business restructuring

and business model optimization, transfer pricing

documentation, assistance in tax audits and risk

assessments, intangible valuation and corporate finance.


transfer pricing:

Commentaries on relevant Case Law


Degrees and

qualifications:

Masters in Corporate Taxation

Universidad Pontificia de Comillas (ICADE)

Degree in Law, Degree in Business Administration

Universidad Carlos III de Madrid


representations in

groups/committees



related matters:

Participation in business transfer pricing forums (BIAC,

UN, Business Europe)


Name and surname: Mrs. Susana Bokobo


Position: Associate Director of Fiscal Policies and Global Practices

in the Tax Affairs Department

Title: Dr.



transfer pricing:

Responsible in Repsol Group for the coordination and

implementation of tax policy in a wide range of areas:

corporate tax, litigation, finance, R&D incentives, risk

assessment and transfer pricing.


experience:

Before joining Repsol, Susana spent four years working

as an Attorney in Law in the Supreme Court of Spain

(2007-2011), specializing in corporate tax issues. Her

duties included drafting rulings and writing reports on

specific issues on request, concerning double taxation in

corporate tax, European taxation, tax penalties, transfer

pricing, tax regime of pensions. 2003-2006 she was Tax

Advisor for the Institute For Fiscal Affairs (accountable

to the Ministry of Finance) and she is Associate

Professor of Tax Law.


transfer pricing:


Degrees and

qualifications:

Bachelor's Degree in Law (1991) Phd in Tax Law, with honours (1996) Diploma in Accounting and Finance (2015)


representations in

groups/committees



related matters:

Actively participating member of the respective Tax

Committees of BIAC, BusinessEurope, the International

Chamber of Commerce and the UN Subcommittee on

Extractive Industries Taxation for Developing Countries.

TPCA (Transfer Pricing Center Association – Stowarzyszene

Centrum Cen Transferowych)

(Organisation) name: TPCA (Transfer Pricing Center Association -

Stowarzyszenie Centrum Cen Transferowych)

Acronym: TPCA



307863718411-66

Website: http://cct.org.pl/

Category: Association

and more precisely: Business association

Countries/Areas

represented:

Poland


the organisation:

“Transfer Pricing Centre” Association is a non-profit

organization aimed at promoting transfer pricing

knowledge in Poland, founded by specialists working for

capital groups in Poland, mainly in energy and industry

sector.

Association devoted to promoting transfer pricing

knowledge in Poland. Responsible for participation in

legislative processes and taking part in public

consultations at the OECD WP6. The association is the

first and only independent organisation in Poland of in-

house transfer pricing business professionals, focusing

on needs and expectations of businesses and covering a

broad range of taxation issues arising in capital groups.


represented:

Energy, Industry

Level of interests

represented:


Name and surname: Sylwia Rzymkowska

Nationality: Polish

Position: Chairman of the Transfer Pricing Centre Association

Stowarzyszenie Centrum Cen Transferowych

Title: Chairman



transfer pricing:

Sylwia is a certified tax advisor in Poland, who - for over

14 years - has been involved in transfer pricing issues.

Sylwia has experience in general tax advisory,

specialized in transfer pricing, corporate income tax and

international tax, currently holds a position of Transfer

Pricing Specialist at Polish Oil and Gas Company (PGNiG).

Sylwia holds the position of Chairman of the Transfer

Pricing Centre - the association dedicated to promoting

transfer pricing knowledge in Poland - where she is

responsible for participating in legislative processes. Her

expertise includes: tax consultancy, transfer pricing,

international taxation, APAs.

Author and co-author of several transfer pricing

publications.

Sylwia brings together experience in the public sector

(Ministry of Finance), consulting (Big 5 firms), business

and volunteering (Transfer Pricing Centre Association,

Business Centre Club in Poland).


experience:

Prior to PGNiG, for 5 years, Sylwia had held the position

of Senior Specialist at Ministry of Finance (Income Taxes

Department, APA Team) that is responsible for

conducting APA procedures and preparing binding

rulings on double tax treaties. As a Polish delegate to a

number of meetings of OECD's Working Party No 6 on

Taxation of Multinational Enterprises Sylwia participated

in consultations with business community regarding the

discussion draft on Transfer Pricing Aspects of Business

Restructuring. As an expert trainer for the tax

administration on double tax treaties she has been

specialising in the issues of permanent establishment

and transfer pricing. She has been a member of the

delegation negotiating the double tax treaty with the

United States.


transfer pricing:

Transfer pricing and state aid - procedure relating to

Starbucks by the European Commission, Monitor

Podatkowy/Tax Monitor, April 2015

Brussels will investigate corporations Rzeczpospolita

January 19,2015

Associated enterprises WoItersKluwer September 24,

2014, Book on associated enterprises, transfer pricing

and TP documentation. Book edited by prof.

Włodzimierz Nykiel and dr Dariusz Strzelec. Chapter on

definition of associated enterprises

New guidelines for intangibles - summary of OECD

consultation Przegląd Podatkowy/Tax Review January

2013

Initial experience with APA practice and update on

recent changes to APA procedures, International

Transfer Pricing Journal, March 2007

TP documentation for services and other intangible

transactions Monitor Podatkowy/Tах Monitor June 2004

Authors: Sylwia Rzymkowska, KrystynaSzydłowska

TP documentation tor tangible transactions Monitor

Podatkowy/Tax Monitor May 2004 Authors: Sylwia

Rzymkowska, Krystyna Szydłowska

Transfer prices in the context of tax due Przegląd

Podatkowy/Tax Review June 2003 Authors: Sylwia

Rzymkowska, Rafał Gołaj


Degrees and

qualifications:

Warsaw University, Economic Sciences Department

Graduate of the Economic Sciences Department: of the

University of Warsaw, Master of Economics, MA thesis:

"Tax havens" (2000)

Certified tax advisor in Poland (No. 10075)


representations in

groups/committees



related matters:

Transfer pricing expert at Business Centre Club in Poland

(pro bono)

1

AB Volvo

(Organisation) name: AB Volvo

Acronym: Volvo



51773601133-57

Website: www.volvo.com

Category: Corporate

and more precisely:

Countries/Areas

represented:

Sweden


the organisation:

The Volvo Group is one of the world’s leading

manufacturers of trucks, buses, construction equipment

and drive systems for marine and industrial applications.

The Group’s vision is to become the world leader in

sustainable transport solutions and performs everything

from blue sky research and development to end

customer sale financing. The Group, with its

headquarters in Gothenburg, employs close to 100 000

people and has production facilities in 19 countries and

sale of products in more than 190 markets. In 2014 the

Volvo Group’s net sales amounted to about SEK 283

billion. AB Volvo is the ultimate parent of the Volvo

Group which consists of some 300 legal entities

worldwide.


represented:

Automotive industry

Level of interests

represented:

National (Sweden) Regional/local

2


Name and surname: Jesper Barenfeld

Nationality: Swedish

Position: Senior VP, Head of Corporate Tax, Volvo Group

Headquarters, AB Volvo

Title: Dr.



transfer pricing:

Dr. Jesper Barenfeld is the head of tax of the Volvo

Group with an extensive experience in the area of

international taxation and with much of the day-to-day

work focusing on transfer pricing. Dr. Barenfeld’s work

experience includes M&As, divestments and

implementation of the Group’s Transfer Pricing-model

as well as APAs, tax audits and litigations in the Transfer

Pricing area.


experience:

Before joining the Volvo Group in 2008, Dr. Barenfeld

worked for the Confederation of Swedish Enterprise on

international taxation and EC tax law.


transfer pricing:


Degrees and

qualifications:

Dr. Barenfeld graduated as Doctor of Laws in 2005


representations in

groups/committees



related matters:

Member Business Industry Advisory Committee to the

OECD (BIAC) – Committee on Taxation and Fiscal Policy

(2008 –); Member BusinessEurope Tax Policy Group

(2008 –); Member International Chamber of Commerce

(ICC) – Commission on Taxation (2008 –); Board Member

International Fiscal Association, Swedish branch (June

2011 –); Member of Näringslivets Skattedelegation

(January 2015 –

3


Name and surname: Anders Allvin

Nationality: Swedish

Position: Senior Tax Director, Transfer Pricing

Title: Jur kand, L.L. M



transfer pricing:

Senior Tax Director Transfer Pricing, Volvo Group


experience:

Partner, Svalner Skatt & Transaktion, Stockholm (2

years) following 9 years of experience in Transfer Pricing

at PricewaterhouseCoopers (New York and Stockholm)


transfer pricing:

Published several articles in SkatteNytt on transfer

pricing


Degrees and

qualifications:

Master of Law Program (L.L.M), University of Georgia,

Athens, U.S. (1999)

Lund University Faculty of Law, Lund, Sweden (L.L.M),

Specialisation: International Taxation (1996)

Trier University Faculty of Law, Germany ; German civil

law studies (1996)


representations in

groups/committees



related matters:

CMS Bureau Francis Lefebvre (Chair)

Documents

Transcript of CMS Bureau Francis Lefebvre (Chair)